3
Shared Docs
3
Same-Page
6 / 3
Mentions
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 and #2 I. UNITED STATES JOINT STATEMENT OF UNDISPUTED FACTS The parties hereby stipulate and agree that the following facts are not in dispute and may be accepted as true
ensued between the United States and Epstein. Despite the investigation revealing that Epstein had molested more than 40 minor girls, in Late 2007, the United Stales entered into a non- prosecution agreement (NPA) with Epstein - esseNiatly egree:ng to immunize Epstein for al of the Federal Sex crimes he committed
copy of the terms was not provided. A notification was not provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the United States was prepared to name in an indictment. As a result, Jane Doe #2 never received a notification a letter about the agreement. The-rietifieation4id-net
on the [NPA] when seeking civil relief against Epstein . . . and affirmatively advanced the terms of the [NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13. After reaping the benefits of the NPA, the
ceedings, we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally- negotiated plea deal. The Washington Post Company hnp://vAvw.washingtonpost.com/newsivolokh-conspiracyiwpf2014/04/21/eleventh-circuit-r... 5/2/2014 EFTA00191355 catinc6W-WIStsaiff I51561.40fir2t
F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for federal offenses, and the intervenors' disclosure of their work product waive
edings, we will be able to prove that clear violation of the CVRA and then obtain the remedy of invalidating the illegally- negotiated plea deal. O The Washington Post Company http://www.washingtonpost.com/news/volokh-conspiracy/wp/2014/04/21/eleventh-circuit-r... 5/2/2014 EFTA00605735 Appeals court rules against sex of
5 PM To: Jeffrey E. Subject: Re: he forgets Amazing. > Brad S. Karp Chairman Paul, Weiss, Rifkind, Wharton & Garrison =LP 1285 Avenue of the Americas I New York,&=bsp;NY 10019-6064 (Direct Phone) I (Direct Fax) I http://www.paulweiss.com Bio: https://www.paulweiss.com/professionals/partners-and
Toronto, Ontario Allan E. Gotlieb Bennett Jones LLP Toronto, Ontario Bill Graham Canadian House of Commons Ottawa, Ontario Donald E. Graham CEO of The Washington Post Company Washington,=D.C. Jeffrey W. Greenberg Aquiline Capital Partners, LLC New York, N=Y. Richard N. Haass President, Council on Foreign Relations New Yo
Entities connected to both United States and The Washington Post Company

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Ghislaine Maxwell
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSONJane Doe
PERSONFBI
ORGANIZATION
Kenneth Marra
PERSON
Bradley Edwards
PERSON
Prince Charles
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMartin Weinberg
PERSON
Paul Cassell
PERSONRoy Black
PERSON
Palm Beach
LOCATION
Atlanta
LOCATION
Palm Beach County
LOCATION